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461 Common Street, PMB365 Belmont, Massachusetts 02478 617-484-4171 617-484-4941 (FAX)

October 23,2000

VIA FEDERAL EXPRESS

Office of General Counsel . ... Federal Election Commission 999 E Street, N.W. Washington, DC 20463

Re: MUR5110 Dear Sir or Madam:

On behalf of UTV of San Francisco, Inc., licensee of television station KBHK-TV, I am transmitting a response to your letter of October 9,2000in the above-referenced matter.

If there are any questions, or if you need any further information, please let me know.

YQurs truly,

Francisco, Inc.

MJD/jf

Enclosure

cc: Gerard R. Braet

\\WC - 61619B -#1201490 vl ....

October 20,2000 BAY ARE% CABLE12

JERRY BRAET

Vice President 8 Office of General Counsel Federal Election Commission ’ General Manager 999 E Street, N.W. UNITED Washington, DC 20463 PARAMOUNT

NETWORK RE: MUR5110 Dear Sir or Madam:

On behalf of UTV of San Francisco, Inc. (“UTV”), licensee of television station KBHK-TV, channel 44, San Francisco, California, I am responding to your letter of October 9,2000,and to the complaint dated September 26, 2000, from David A. ‘Blake. Mr. Blake has alleged that KBHK-TV broadcast a paid political advertisement from 10 to 11 am PDT on September 26 “under the aegis of something called CBN, the Christian Broadcasting Network.”

The facts are as follows. The program in question was not a paid political advertisement but rather The 700 Club, a television program fiom the Christian Broadcasting Network (“CBN”) that airs weekdays before a studio audience from CBN’s broadcast facilities in Virginia Beach, Virginia, and which KBHK-TV has broadcast on a delayed basis for approximately two years. KBHK-TV is compensated by CBN for these broadcasts and broadcasts a notice at the beginning of each program stating, “This program is paid for by THE CHRISTIAN BROADCASTING NETWORK.” We also broadcast a notice stating “The views expressed in the [followingl [preceding] program are not necessarily those of UPN44Digital45 .”

According to CBN (see the attached Fact Sheet):

The 700 Club is a newdmagazine program that has the variety and pacing of a morning show with in-depth investigative reporting by the CBN News team.. .. On the air continuously since 1966, it is one of the longest-running programs in broadcast history. Hosted by Pat Robertson, Terry Meeuwsen, Lisa Ryan and Gordon Robertson with news anchor Lee Webb, The 700 Club is a mix of news and commentary, interviews, feature stories and Christian ministry. The program is carried on Fox Family Channel cable network, FamilyNet, Trinity Broadcasting Network, and numerous U.S. television stations and is seen daily by approximately 1 million homes. The international edition of The 700 Club has been seen in approximately 60 foreign countries

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. KBHK TV 650 California Street San Francisco California Ck3fEL Braet 94 108-2702 resident and General Manager

Tel. 41 5.249.4400 Fax 415.397.1924 Internet [email protected] 0 A ...... - 10/16/00 16: 41 la 002 Fact Sheet- Public Relations Division. The Chri&n Broadcasting Network

THE 700 CLUB DESCRIPTION fie 700 CZ& is a live teIevision plrograrn that airs weekdays before a studio auditwe from The Christian Broadcasting Network's {CBN) broadcast facilities in Virginia Beach, Virginia, On the air continuously since 1966, it is one of the Iongest-ruMing programs in broadcast history. Hbsted by Pat Robertson, Terry Meeuwsen, Lisa Ryan, and Gordon Robertson, with news atl~h~tLee Webb, % 700 Club is a mix of news and commentary, interviews, fesrtute stories, and Christian ministry. The ptagam is carried on Fox Family Channel cable network, FamilyNet, Trinity B~mdwstmg Network, and numerous U.S. television stations and is seen daily by approximately one million homes. The intamtima! edition ofme 700 Club has hen seen in approximateIy 60 foreign countries. 977 Centerville Tumpb, Virginia Beach, Virginia 23463 Andy Freeman, Vice President of hgramnhgExecutive Producer Bmke Boland, 2% 700 CZub Senior Producer STRUCTURE Z'k 700 Club is a nswslmagazine program that has the varim and pacing of a morning show with in-degth investigative reporting by the CBN News team. Whether reporting live fiom the scene of a terrorist attack or a MWdisaster, CBN News brings coverage on major events afRzt.hg our nation. The Washipgtan Bveau reports on news 6rom the capitol and correspondents repart on events and trends that shape the world hmMascow to Jerusalem. me 700 CZub also includes live guests, speciat fmand P~US~CL BACKGROUND Zh700 Club television program is an outgrowth of I 1963 te1ethm in which founder Pat Robertson asked 700 viewers to join the '(700 Club" by pledging $10 a month, money needed to meet CBN"' monthly budget AAer a very successfirt "700 Club" telethon in 1966, Robertson decided to add to the end of his station's bdcast day a progranr with a fonnat of prayer and midm ooupled with telephone response. He named it 700 Club, hoping to build a nationwide audience based on this earlier success. lk 700 Club rurw airs in nearly 90 million homes and averages abdrrt one million viewers on a daily basis. HIGHLIGHTS Over the years 27~700 CIub has become well known for its hsh and insightful interviews, hard-hitting special reports, and dramatic features. Some recent highlights include: International news coverage on the persecution of Christians in Sudan, Pakistan, Cambodia, Bangladm4 Egypt, China, Burma and Indonesia; ]Russian economic meltdtnvn; Istaeli election; Koswo crisis; and the nwlear proliferation in Iraq, Iran, and North Korea were CbVd. CBN News guests include Tom Delay and fomer Israeli Prime Minister Netanyahu. Appearance by sports celebrities Reggie White, Jeff Gordon, and Hersbal Wab, show business personaIitieS Lynn Whitfield, Billy Banks, Dyan Cannon, Maria Shtivm, Richard Karn, Chuck Narris, Charlton Heston, Gary Busey, fithie L,ee Gifford, John WaIsh, Jane Robelot, and Dr. Laura. Features including: "unsung Hem'' segments highlighting people who quietly devote their time to helping Others; and dramatic life changing stories of people who believe in the POWM of hith md pra~,testimonies of dramatic healings. Sports features and celebrities Chad Chiligk-the head coach of the Dallas Cowboys, John Smoltz-outstauding pitcher of the Athh Braves, and yearly c~vmgeof the Superbowl, F'wl Four, World Series, md special wmts like the Ironman Triathlon mm@~on. 415-397-1924 TU'44 61PEE OCT 16 '08 16:45

STATEMEMT.OF DESIGNATION OF COUNSEL

NAME OF COUNSEL: Karvin J. Diamond I Esq FIRM: Law Offices of Illamin J. Diamond \

ADORESS:,464 Copnon Street, PMB365 Belmont, Fassach.usetts 02478

3 :yy iit!$2 The above-named individual is hereby designated 8s my counsel and is authorized to receive any nothations and other communications from the Commission and e Commig.sion.

/B//l/dD Date

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